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Paragraph 29 of the Ruling is also amended to delete the second sentence and to substitute the following: As consideration therefor, Sibling 3 Co will issue XXXXXXXXXX Special A Shares to Sibling 3. Paragraph 30 of the Ruling is also amended to delete the second sentence and to substitute the following: As consideration therefor, Sibling 1 Co will issue XXXXXXXXXX Special A Shares to Sibling 1. ... Paragraph 36 of the Ruling is amended to delete the second sentence and to substitute the following: As consideration therefor, TG II will issue XXXXXXXXXX Special C Shares to DE. ...

Accordingly, the Fee is not a payment made by the borrower in respect of borrowed money as consideration for a reduction in the rate of interest payable for purposes of subsection 18(9.1). ... Paragraph 18(9.1)(c) Paragraph 18(9.1)(c) refers to payments made as consideration for a reduction in the rate of interest payable by the taxpayer on the debt obligation. ... Accordingly, the Fee is not, in our view, a payment made by B Co in respect of borrowed money as consideration for a reduction in the rate of interest payable. ...

Principal Issues: Cost of shares acquired as a result of a foreign merger Position: Cost of shares includes an amount equal to the fair market value of the consideration given to acquire such shares. ... (i) At the Effective Time, Mergeco will issue common shares (the "New Mergeco Shares") to Holdco in consideration for Holdco issuing the Holdco Note and the New Holdco Shares to Canco (as described in paragraph 10(h) above). ... (k) Canco will add to the stated capital account of the Canco common shares issued to the former Targetco shareholders an amount equal to the Holdco Consideration Amount (which equals the Mergeco Consideration Amount) less any amounts paid by Canco to such shareholders in lieu of the issuance of fractional shares. ...

Trust B1 will transfer: (a) all of its Class XXXXXXXXXX Shares of DC to Holdco B and, as consideration therefor, Holdco B will issue to Trust B1 a number of its Class C Preference Shares having an aggregate FMV equal to the aggregate FMV, at that time, of the Class XXXXXXXXXX Shares of DC transferred to it by Trust B1. ... Trust B2 will transfer: (a) all of its Class XXXXXXXXXX Shares of DC to Holdco B and, as consideration therefor, Holdco B will issue to Trust B2 a number of its Class D Preference Shares having an aggregate FMV equal to the aggregate FMV, at that time, of the Class XXXXXXXXXX Shares of DC transferred to it by Trust B2. ... Trust S1 will transfer: (a) all of its Class XXXXXXXXXX Shares of DC to Holdco S and, as consideration therefor, Holdco S will issue to Trust S1 a number of its Class B Preference Shares having an aggregate FMV equal to the aggregate FMV, at that time, of the Class XXXXXXXXXX Shares of DC transferred to it by Trust S1. ...

In closing you requested our consideration of these issues with the view to possibly amending the current RCA rules in the Act. ... Wilson, Minister of Finance, we will arrange to have your letter forwarded to his office for consideration. ...

28 May 1991 Internal T.I. 91M05087 F- Paid-up Capital of Shares Owned by Non-resident Unedited CRA Tags 84.1, 212.1 Q. 26:  Paid-up capital of shares owned by non-resident Section 84.1 permits a transferor to receive, without triggering a  deemed dividend, non-share consideration having a value equal to the greater of the adjusted cost base and the paid-up capital of the shares being transferred.  However, the maximum value of the non-share consideration that a non-resident transferor can receive, without triggering a deemed dividend under section 212.1, is equal to the paid up capital of the transferred shares. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that he will receive the utmost consideration possible in the resolution of this case. ...

28 February 1980 Income Tax Severed Letter RCT 85-043 F Unedited CRA Tags 85.1 Dear XXX This is in reply to your letter dated February 28, 1980 in which you asked whether or not the comments in Interpretation Bulletin IT-115R concerning the receipt of cash or other consideration in lieu of fractional shares, also applies when such consideration is in lieu of fractional shares arising on a share for share exchange pursuant to section 85.1 of the Income Tax Act. ...

ConsIderation of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that he will receive the utmost consideration possible in the resolution of his case. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and the evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of her case. ...